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Showing content with the highest reputation on 06/30/2014 in Posts

  1. EPCRS (RP 2013-12) Section 6.02(5)( c )... ( c ) Recovery of small Overpayments. Generally, if the total amount of an Overpayment to a participant or beneficiary is $100 or less, the Plan Sponsor is not required to seek the return of the Overpayment from the participant or beneficiary. The Plan Sponsor is not required to notify the participant or beneficiary that the Overpayment is not eligible for favorable tax treatment accorded to distributions from the plan (and, specifically, is not eligible for tax-free rollover).
    2 points
  2. I think that is the cleaner way to do it.
    1 point
  3. If the plan reallocates forf I would think about having the employer making plan whole so no one can say the other people in the plan were harmed.
    1 point
  4. On principal I would not do anything. Sometimes I think people just need to take a deep breath and ask "is this really a big deal"? We leave small over-deposits in peoples accounts fairly often (Johnny was over-deposited by $8, etc.). If they're underpaid that is different, we usually correct all under-payments. But tiny little overpayments?
    1 point
  5. We the real answer is the trustee is supposed to make every reasonable effort to recover the over payment. The reality is the amount involved is so small that it would probably cost more to recover it than any potential recovery. I'd probably send a letter to the participant requesting a return of the over payment and keep that in the file. But I would probably not followup to hard when the participant files that letter in his/her circular file.
    1 point
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